Specific penalty notice requirement invalidates concealment penalty where the applicable statutory charge was not clearly identified.

A penalty for concealment of income requires a valid notice that clearly identifies whether the charge is concealment of income or furnishing inaccurate particulars. The notes state that the foundational notice referred to both statutory limbs without specifying the applicable charge, and a subsequent notice did not cure that defect because the penalty order was made before the response period under that notice expired. Clear satisfaction and a specific notice are therefore presented as indispensable requirements for penalty proceedings, resulting in deletion of the penalty.

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Issues: Whether penalty for concealment of income under section 271(1)(c) could be sustained where the foundational notice under section 274 did not specify the applicable limb or charge.

Analysis: The notice dated 30.03.2014 referred alternatively to concealment of particulars of income or furnishing inaccurate particulars without identifying the precise charge. The later notice specifying concealment afforded time until 13.04.2018 for response, but the penalty order was made on 30.03.2018, before that date. A valid, specific notice and clear satisfaction regarding the applicable statutory limb are indispensable in penal proceedings; the defect in the foundational notice was not cured by the later notice.

Conclusion: The penalty under section 271(1)(c) was invalid and was deleted, in favour of the assessee.

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